Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:01-cv-02198-PCD

Document 456

Filed 03/02/2005

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------------------------------x SECURITY INSURANCE COMPANY OF : HARTFORD, : : CIVIL NO. 301CV2198(PCD) Plaintiff, : : v. : : TRUSTMARK INSURANCE COMPANY, : : Defendant. : : ---------------------------------------------------------------x TRUSTMARK INSURANCE COMPANY, : : Third Party Plaintiff, : : v. : : TIG INSURANCE COMPANY, : : Third Party Defendant. : : MARCH 2, 2005 ---------------------------------------------------------------x SECURITY INSURANCE COMPANY OF HARTFORD'S UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to Local Rule 7, the Plaintiff, Security Insurance Company of Hartford ("Security"), hereby moves for an extension of time to file its reply brief in support of its Motion to Strike Portions of Defendant Trustmark Insurance Company's Amended and Supplement Response to Security's Second Set of Interrogatories and to Compel Trustmark to Verify its Original Response to Security's Second Set of Interrogatories. Said Motion to Strike was served on counsel for Trustmark pursuant to this Court's supplemental order on January 31, 2005.

NO ORAL ARGUMENT REQUESTED

Case 3:01-cv-02198-PCD

Document 456

Filed 03/02/2005

Page 2 of 4

Trustmark served its opposition to Security on February 22, 2005. Security's reply brief is currently due on March 8, 2005. Security seeks an extension of time of 3 days, until March 11, 2005 to file its reply brief in support of its motion to strike. There is good cause for granting this motion for extension of time in that Security's counsel will be completing Part A of its pretrial memo which is also due on March 8, 2005. Counsel for Security has consulted with counsel for Trustmark, and Trustmark does not oppose this motion for extension of time. This is the first motion for extension of time that Security has sought related to this motion to strike.

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Case 3:01-cv-02198-PCD

Document 456

Filed 03/02/2005

Page 3 of 4

WHEREFORE, Security respectfully requests an extension of time, until March 11, 2005 to file its reply brief in support of its motion to strike.

Respectfully Submitted, SECURITY INSURANCE COMPANY OF HARTFORD By___________________________ Frank F. Coulom, Jr. (ct 05230) Marion B. Manzo (ct 22068) Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103-3597 Tel. No.: (860) 275-8200 Fax No.: (860) 275-8299 Mark B. Holton (ct 21727) Kathryn E. Nealon (ct 22754) Gibson, Dunn & Crutcher LLP 200 Park Avenue New York, New York 10166 Tel. (212) 351-4000 Fax (212) 351-4035 David J. Grais (ct 23352) Kathryn C. Ellsworth (ct 24988) Dewey Ballantine LLP 1301 Avenue of the Americas New York, New York 10019 Tel. (212) 259-8000 Fax (212) 259-6333

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Case 3:01-cv-02198-PCD

Document 456

Filed 03/02/2005

Page 4 of 4

CERTIFICATION This is to certify that a copy of the foregoing was sent via facsimile and first-class mail, postage prepaid, to the following on this 2nd day of March, 2005: John Bannon, Esq. Schiff Hardin & Waite 6600 Sears Tower Chicago, Illinois 60606-6473 David R. Schaefer, Esq. Brenner, Saltzman & Wallman LLP 271 Whitney Avenue New Haven, CT 06511 David A. Slossberg, Esq. Hurwitz & Sagarin 147 North Broad Street Milford, CT 06460-0112 Harry P. Cohen, Esq. Cadwalader, Wickersham & Taft One World Financial Center New York, NY 10281 ______________________________ Marion B. Manzo

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